Ray Anthony Chaney v. United States
658 F. App'x 984
| 11th Cir. | 2016Background
- Plaintiff Ray Chaney, a federal inmate with a preexisting Dupuytren contracture and chronic pain in his left fifth finger, sought surgery while incarcerated at USP Atlanta after reinjuring the finger.
- Prison physicians (Dr. Martin and Dr. Winston) requested orthopedic consultations; the regional Utilization Review Committee (URC) approved an April 3, 2012 surgery at Grady Hospital, but Chaney was not transported to the hospital and the operation was not performed; record lacks evidence explaining why he was not taken.
- Subsequent specialist exams produced mixed opinions: some providers later concluded surgery was unlikely to restore normal function or alleviate Chaney’s palm pain; later URC denials and approvals followed for additional consultations.
- After a later appointment, Chaney fell exiting a transport van while shackled; Officer Young did not assist him and Chaney alleged exacerbation of his hand injury.
- Chaney filed an administrative tort claim (denied) and then sued under the FTCA and (liberally construed) asserted Eighth Amendment Bivens claims; the United States was substituted as defendant. Both parties moved for summary judgment; the district court granted the government’s motion and denied Chaney’s. The Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chaney may rely on a negligence claim for failure to transport him to scheduled surgery | Chaney argued prison transportation employees negligently failed to bring him to his scheduled surgery, causing harm | Government argued this claim was not pled and was raised for the first time in opposition to summary judgment; therefore untimely | Court held the transportation-neglect claim was raised first in Chaney’s summary‑judgment brief and was not in the complaint; district court properly refused to consider it |
| Whether prison officials were deliberately indifferent in violation of the Eighth Amendment by delaying/denying surgery | Chaney argued delays and cancellations of surgery showed subjective awareness and disregard of a serious medical need, causing permanent injury | Government showed prison doctors ordered consultations and URC approved consults/surgery; denied deliberate indifference due to lack of evidence of subjective knowledge or conscious disregard | Court held Chaney failed to produce evidence of subjective knowledge and deliberate indifference by the doctors, URC, or regional medical director; summary judgment proper |
| Whether Officer Young was negligent in failing to assist Chaney exiting the transport van under the FTCA | Chaney argued Officer Young’s failure to assist caused his fall and worsened his injury | Government invoked the FTCA discretionary‑function exception: Officer Young’s decision involved judgment and policy considerations (safety) and thus is immune | Court held Officer Young’s conduct was a discretionary function grounded in policy considerations; FTCA immunity applies |
| Whether summary judgment or denial of counsel/brief deadline extensions were abused | Chaney argued procedural errors (reply deadline extension; denial of appointed counsel) were abusive | Government defended district court’s management as within discretion | Court held no abuse of discretion on those procedural rulings |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (recognized judicial remedy for constitutional violations by federal officers)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference standard for medical care)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective knowledge and drawing of inference requirement for Eighth Amendment claims)
- Townsend v. Jefferson Cty., 601 F.3d 1152 (11th Cir. 2010) (elements required to prove deliberate indifference in prison medical care claims)
- Gilmour v. Gates, McDonald & Co., 382 F.3d 1312 (11th Cir. 2004) (cannot raise new claims for first time in opposition to summary judgment; must amend complaint)
- Cranford v. United States, 466 F.3d 955 (11th Cir. 2006) (two‑part test for FTCA discretionary‑function exception)
- Hamilton v. Southland Christian Sch., Inc., 680 F.3d 1316 (11th Cir. 2012) (standard of review for summary judgment; view evidence in light most favorable to non‑movant)
- Campbell v. Air Jam. Ltd., 760 F.3d 1165 (11th Cir. 2014) (pro se pleadings are construed liberally but litigants must follow procedural rules)